U.S. Nuclear Regulatory Commission

Clarification of Certain Requirements for Exclusive-Use Shipments of Radioactive Materials

HPPOS-084 PDR-9111210232

Title: Clarification of Certain Requirements for

Exclusive-Use Shipments of Radioactive Materials

See IE Information Notice No. 80-32 dated August 29, 1980.

This notice clarifies requirements regarding open and

closed transport vehicles, personnel barriers, packages

enclosed within an outer cask shield, exclusive-use

shipments, and radiation limits. See Revision 1 to this IE

information notice (HPPOS-085).

In mid-1979, NRC initiated an enhanced program for

inspection of shipments of radiation materials. This

augmented inspection / enforcement program prompted a number

of questions on the proper application of certain

regulatory requirements. These questions involved the

problems and deficiencies associated with exclusive-use

highway shipments of low-level radioactive wastes. The

purpose of this Notice is to discuss the following fourteen

questions to clarify the application of certain

requirements, particularly the application of the limits of

radiation levels of exclusive-use shipments as prescribed

in 49 CFR 173.393 (j).

1.What limits would apply to packages being transported on

an open, exclusive-use transport vehicle?

2.What constitutes a closed transport vehicle?

3.In the situation described above, is such a "personnel

barrier" considered to be the "package" or a component of

the package?

4.In the above situation, what are the limits for radiation

levels on the packages within such a personnel barrier?

5.If "packages" such as drums are enclosed within an outer

cask "shield" (as opposed to a personnel barrier or closed

vehicle) wherein the other shield is necessary to achieve

compliance with the limit of either 173.393 (i) or 173.393

(j), may the inner drum (s) be considered to be the

"package"?

6.In the situation described above, would the levels of

radiation on the inner drums be limited to the levels of

173.393 (j) (1) (e.g., 1000 mrem/hr at 3 ft)?

7.In monitoring the radiation levels at the external

surface of the transport vehicle, as prescribed in 173.393

(j) (2), do the limits apply at the bottom and top of the

vehicle, as well as at the sides?

8.In the above situation, does this mean that in applying

the limit of 173.393 (j) (3) (e.g., 10 mrem/hr at 6 ft from

the sides of the vehicle) the limit also applies at the top

and "bottom" of the vehicle?

9.In 173.393 (j) (3) the radiation level limit is

prescribed at 10 mrem/hr at 2 m (6 ft) from the outer

lateral surfaces of an exclusive-use vehicle. Since 2 m is

6.6 ft, which limit would apply (6 ft or 6.6 ft)?

10.What is an "exclusive-use" shipment?

11.Frequently shipments of radioactive waste are made as

"exclusive-use" shipments under arrangements whereby the

original generator of the waste utilizes the services of a

waste collector (i.e., "broker) who in turn usually engages

a common or contract carrier to transport the shipment or

transport the material in his own vehicle as a private

carrier. On occasion this "broker" may also be the

consignee (e.g., a waste burial site operator). Because of

this complex arrangement, confusion often arises as to

which party is responsible for performing the regulatory

requirements of the "shipper" or "consignor." Can you

clarify this?

12.In the above situation, assume that a "broker" picks up

or arranges for pickup radioactive waste from more than one

generator's facility for transport as a single shipment by

a common carrier or by himself as a private carrier. Is it

not required that an exclusive-use shipment be from a

"single consignor"?

13.In an exclusive-use shipment of LSA materials, the

shipper is required by 173.392 (c) (9) to provide specific

instructions to the carrier for maintenance of

exclusive-use shipment controls. What should such specific

instructions include?

14.49 CFR 173.393 (j) (4) requires that the radiation level

in any "... normally occupied position in the car or

vehicle ..." be limited to 2 mrem/hr. Where should this

limit be applied in a tractor with a sleeper cab?

Regulatory references: 10 CFR 71, 49 CFR 173

Subject codes: 7.1, 12.17

Applicability: All